21 March 2007 SRTN 2007/01 Building Societies Statistical Reporting Transition Notice Would recipients of this notice please ensure that these details are passed on to the members of their staff who are responsible for the transition to Bank of England reporting forms with effect from 1st January 2008. Statistical reporting transition notices will be issued to building societies during the period of transition from FSA reporting to reporting statistical information to the Bank of England (with effect from 1st January 2008). The notices will provide important information and guidance to societies regarding the reporting of Bank of England returns. This notice provides details of the outcome of the review of Bank of England statistical reporting forms and thresholds, which was mentioned at the Building Society Reporting seminar in November 2006. All of the changes take effect prior to the Building Societies starting to report Bank of England statistical returns. It is important that building societies use the new forms in preparation for reporting to the Bank of England in 2008. These new forms can be found at www.bankofengland.co.uk/statistics/reporters/defs/new_defs.htm. This notice contains a section for each form providing information on the implementation dates for the new forms, including the implications for building society reporting, the new reporting thresholds and, for information, the changes agreed as part of the rolling review of forms. An updated mapping document (between the relevant FSA building society returns and the new Bank of England returns) has been posted on the internet. Letters providing details of reporting requirements from January 2008 will be sent to each building society individually by Easter 2007. This notice covers: 1. Rolling review of statistical reporting forms 2. Form BT 3. Form BE 4. Forms AD and AL 5. Discontinuation and replacement of Form Q1(D) by new Forms IS, IC and IO 6. Forms CA, CC and CL 7. Discontinuation and replacement of Form QX by new Forms CX, WO and HF 8. Form DQ 9. Form DM 10. Forms HI and HO 11. Form PL and Form ER SRTN2007/01 Page 1 of 15 1. Rolling review of statistical reporting forms In April 2004, the Bank issued a new Statistical Code of Practice outlining its approach to collecting, compiling and publishing statistical data. The Code includes an aim to balance the needs of users against the demands placed on suppliers. In late 2004, a project was launched to develop cost-benefit analysis tools that could be used to achieve this balance. As part of this, a rolling review of all statistical returns was initiated and the results of individual reviews announced in various Statistical Notices. This Notice summarises the results of the latest reviews for several “core” statistical returns and outlines the implementation timetable for these changes. A new page (www.bankofengland.co.uk/statistics/reporters/defs/new_defs.htm) has been created on our website where all of the new versions of the forms, definitions and validations can be downloaded. If you require paper copies of these documents, please contact Antony Ford (Tel. 020 7601 3119, antony.ford@bankofengland.co.uk). The software houses have also been notified of these changes and an updated version of the BEERS Technical Specification has been published and is available from the Bank’s website (www.bankofengland.co.uk/statistics/reporters/electronic/index.htm). If you have any queries about electronic reporting, please contact Leslie Lambert (Tel. 020 7601 4544 or by e-mail at leslie.lambert@bankofengland.co.uk). As part of the reviews, reporting thresholds for the statistical forms have been revised and an updated reporting panel criteria page is included at the end of this notice. 2. Form BT Implementation The first “new” Form BT will be implemented for existing reporters at end-October 2007 data for monthly reporters, and end-December 2007 data for quarterly reporters. Building societies will start reporting from end-January 2008 data for monthly reporters and end-March 2008 for quarterly reporters. However, the Bank may request this form for end-December 2007 data, in addition to the FSA returns, to assist with making adjustments to aggregates affected by the transition between reporting forms. Reporting Threshold The threshold for monthly reporting of Form BT has been set at eligible liabilities (BT£46) in excess of £400mn (positive or negative), or private sector holdings (BT items £2H + £3H or £29D) in excess of £1bn. SRTN2007/01 Page 2 of 15 Form Changes 1) Removals i. The split between interest-bearing and non-interest bearing deposits has been removed from item 2. ii. The identification of interest-bearing sight deposits and the interest-bearing element of retail deposits (BT47A) have been removed from the BT. The latter item has now been added to the BE return (see below). iii. The distinction between gilt and non-gilt repos and reverse repos has been removed. Items previously recorded under Item BT7 have been merged with BT6 and items previously recorded as BT31 have been merged with BT30. iv. Various other boxes have been removed: BT3HA (TESSAs); BT26BA (Eligible local authority bills); BT26DA (eligible bills accepted by UK banks); BT26H and BTAK (Bank of England euro bills); BT28 (lending under DTI special shipbuilding scheme - merged with BT29D); and BTAG (holdings of commercial paper lodged by non-residents, issued by non-residents). 2) Additions i. As a result of discontinuing Form QX (see below) items QX19BL, QX19CD1, QX19CD2, QX19CD3, QX19CD4, QX19CD5 have been moved to the Form BT. The definitions for these boxes are unchanged. Additionally the quoted and un-quoted splits for holdings of investments in UK banks (previously QX32HA, QX32HB and QX32HC) have been moved to the BT; the items BT32AA, BT32AB and BT32AC have been split into separate items (BT32AA1, BT32AA2 etc) for the quoted and un-quoted components. ii. A new box BT19CDA has been added, where reporting institutions are asked to report their levels of inward investment. Capturing this information on Form BT will allow the Bank to measure the level of inward investment for Form HI population monitoring purposes. iii. New boxes BT2BG, BT3BG, BT6BG, BT23DG and BT30BG have been added, which aim to capture business with banking institutions within the same banking group. iv. In Market Notices published in December 2006 and February 2007, the Bank announced details of how it will change the way it finances its foreign exchange reserves. The previous euro note programme is to be replaced with the annual issuance of medium-term securities. The first issue was a US dollar transaction, issued during the week beginning 12 March 2007. To accommodate this change in financing, the coverage of balance sheet items BT32L and BTAL will be broadened to cover all Bank of England securities, whether issued in euro or other currencies (these items previously covered Bank of England euro notes only). The item will therefore be renamed to “Bank of England securities” and an “other currencies” box will be introduced. 3) Other changes SRTN2007/01 Page 3 of 15 i. Section B (items BA, BB, BC) in the appendix will be reported on a levels basis as opposed to a transactions basis. For clarity, we have taken this opportunity to redraft some of the definitions for Form BT. Therefore, any actual definitional changes have been highlighted in the usual way but some additional or revised wording has not. 3. Form BE Implementation The first “new” Form BE will be implemented for existing reporters at end-October 2007 data. Building societies that are requested to report this form will start reporting from end-January 2008 data. However, the Bank may request this form for end-December 2007 data, in addition to the FSA returns, to assist with making adjustments to aggregates affected by the transition between reporting forms. Reporting Threshold The threshold has been set to match that of the Form BT; eligible liabilities (BT£46) in excess of £400mn (positive or negative), or private sector holdings (BT items £2H + £3H or £29D) in excess of £1bn. Form Changes 1) Removals i. The distinction between gilt and non-gilt repos and reverse repos has been removed. Items previously recorded under Item BE7H have been merged with BE6H and items previously recorded as BE31H have been merged with BE30H. 2) Additions i. As a result of discontinuing Form QX (see below) overdrafts for financial corporations, nonfinancial corporations, individuals and individual trusts, unincorporated businesses other than unlimited liability partnerships, and non-profit institutions serving households (previously Form QX section 1) have been moved to the Form BE resulting in all items within item BE29D being re-numbered. Overdrafts are shown first, labelled as BE29DA1, BE29DA2 etc for each of the sectors and Other loans and advances are labelled as BE29DB1, BE29DB2 etc. The re-numbering provides consistency with other sections of the form, with respect to sectors. ii. Also as a result of discontinuing Form QX, the breakdown of securities (including shares and other equity issued by other UK residents) has been moved to the Form BE; item BE32HA will identify quoted shares, item BE32HB will identify unquoted shares and item BE32HC will SRTN2007/01 Page 4 of 15 identify all other securities. 3) Other changes i. Within the deposits section of the form (BE2H sight deposits, BE2HA interest-bearing sight deposits and BE3H time deposits), the category previously classified ‘Households and individual trusts’ has been expanded into two separate categories; ‘Individuals and individual trusts’ and ‘Unincorporated businesses other than unlimited liability partnerships’. ii. To be consistent, the current sector title of ‘Households and individual trusts’ elsewhere on the form has been changed to “Individuals, individual trusts and unincorporated businesses other than unlimited liability partnerships”. There is no definitional change in the content of these items, just a title change for improved clarity. iii. Item BE29D4A (loans and advances to housing associations secured on residential property) has been renamed BE29D2A to reflect it being a component of BE29DA2 or BE29DB2 (non-financial corporations other than public corporations). The item has been shown as an addendum at the bottom of item BE29D, as it comprises overdrafts, other loans and advances. iv. Following the removal of the interest-bearing breakdown of sight deposits on the BT form, the interest-bearing component of the retail deposits item (previously BT47A) has been moved to the BE form (BE47A). 4. Forms AD and AL Implementation The first “new” Form AD and AL will be implemented for existing reporters at end-December 2007 data. Building societies that are requested to report these forms will start reporting from end-March 2008 data. Reporting Threshold The threshold has been set to match that of the Forms BT and BE; eligible liabilities (BT£46) in excess of £400mn (positive or negative), or private sector holdings (BT items £2H + £3H or £29D) in excess of £1bn. Form Changes Form AD is retaining its existing structure and as a result there are no changes to the definitions or internal validations. However, amendments to cross-form validations with Forms BT and BE have been made as a result of the merger of Items 6 and 7 on these forms and the renumbering of item 29D on the Form BE. SRTN2007/01 Page 5 of 15 1) Removals (for Form AL) Data on acceptances and commercial paper will no longer be required and the sections have been removed from the Form. 2) Additions (for Form AL) DTI special scheme lending for shipbuilding for UK ownership (current BT item 28) will be included in AL item 4F “Machinery and equipment not elsewhere classified, and transport equipment”. 5. Discontinuation and replacement of Form Q1(D) by new Forms IS, IC and IO The Form Q1(D) as it currently stands will be discontinued with effect from October 2007, and will be split into 3 new forms: Form IS – Further analysis of secured lending to UK individuals Form IC – Further analysis of credit card lending to UK individuals Form IO – Further analysis of loans and advances to UK individuals These new forms will cover a majority of the data collected via the Q1(D). The exceptions are detailed below. Implementation The three new forms will be introduced for existing reporters from end-October 2007 data. Building societies that are requested to report these forms will start reporting from end-January 2008 data. Reporting Thresholds The reporting thresholds for the new forms will mirror those of the current sections of the Q1(D). These are outstanding loans secured on residential property greater than £1,500mn for Form IS, outstanding credit card balance greater than £100mn for Form IC and outstanding overdraft, loans and advances balances greater than £100mn for Form IO. Form Changes 1) Removals i. Bridging loans (formerly Item QDXFKA) ii. Overdrafts (formerly Item QDXFKC) iii. Item QDXFKF3 “Amounts outstanding on loans covered by items QDXFKF1 – gross lending” iv. The data currently collected in Section D of Form Q1(D), “Other loans to individuals secured on residential property” will no longer be required. SRTN2007/01 Page 6 of 15 2) Additions i. Two new items have been added in each of the new forms: one to measure “amount outstanding of transferred/securitised balances held by entities resident in the UK” and one to measure “amount outstanding of transferred/securitised balances held by entities resident outside the UK”. These new items will help the Bank to improve its data on total amounts outstanding in loans to individuals. ii. Three new items have been added in the Form IS to identify secured lending via offset mortgages. These items will help to improve the Bank’s data on total amounts outstanding in secured loans to individuals and on deposits held by ‘other UK residents’. Item ISXFKBJ1 measures “Amount outstanding excluding the effects of offsetting deposit balances”, item ISXFKBJA measures net “amount outstanding in ‘multiple account’ offset arrangements (ie. where lending balances are offset by deposit balances for interest calculation only)” and item ISXFKBJB measures “Amount outstanding in ‘single account’ offset products” (ie. where lending and deposits are netted as a single balance). 6. Forms CA, CC and CL Implementation The first “new” Forms CA, CC and CL will be submitted by existing reporters for end-December 2007 data. Building societies that are requested to report Form CA will start reporting from end-March 2008 data. Building societies that are requested to report Forms CC and CL will start reporting from end-March 2009 data. Those societies required to report forms CC and CL will be contacted in the first half of 2008. Reporting Threshold Form CA: Threshold has been set to £2,000mn of business in foreign currencies other than euros on either side of the balance sheet; Form CC: Threshold has been set to £300mn external claims; Form CL: Threshold has been set to £300mn external liabilities. Form Changes 1) Removals (for Form CA) i. Currency breakdown for Euro removed. ii. Currency breakdown for Australian dollars, Canadian dollars, Danish kroner, Saudi riyals, Swedish kroner, SDRs and Gold have been combined into “Other Currencies”. iii. Portfolio investments issued by non-residents (items CAC9 + CAC10) have been included in “other assets”. SRTN2007/01 Page 7 of 15 1a) Removals (for Form CC) i. Section A items “revaluation of claims” and “write-offs”. ii. Section B item “claims on non-resident CMIs” 1b) Removals (for Form CL) i. Section B “British Government Stocks held on behalf of non-residents”. 2) Additions (for Form CC) Market loans to non-residents data, currently reporting on Form QX Section 1 (items XC, XC1, XC2 and XC3) have been added to Form CC; as has direct investment in non-residents, currently reported on Form QX (items 32KA, 32KB and 32KC). 2a) Additions (for Form CL) i. Breakdown of deposit and repo liabilities to non-residents data currently reported on Form QX Section 1 (items XB1 and XB2) has been added to Form CL. No additions have been made to Form CA. 7. Discontinuation and replacement of Form QX by new Forms CX, WO and HF The Form QX as it currently stands will be discontinued. Some of the data have been moved across to Forms BT, BE, CC and CL as outlined above and some have been restructured as three new forms: Form CX – Capital expenditure and finance leasing data (replacing parts of QX Sections 1 & 6) Form WO – Write-offs data (replacing QX Sections 4 and 5) Form HF – Foreign direct investment transactions (replacing QX Section 7) Implementation The new Forms CX and HF will be submitted by existing reporters from end-December 2007 data. But Form QX sections 4 and 5 will need to be submitted in the existing manner (section 5 is currently an annual return) for end-December 2007 data, with the new Form WO being submitted for the first time for end-March 2008 data. Building societies that are requested to report Form WO will start reporting from end-March 2008 data. Building societies that are requested to report Form HF will start reporting from end-December 2008 data. Building societies that are requested to report Form CX will start reporting from end-March 2009 data. Those societies required to report forms HF and CX will be contacted in the first half of 2008. Reporting Thresholds Form CX – discretionary but based on fixed assets and finance leasing income. Form WO – greater than £10mn write-offs over the previous calendar year Form HF – greater than £100mn of inward or outward foreign direct investment SRTN2007/01 Page 8 of 15 Some additional information will be required on these forms, as outlined below: 1) Differences between Form QX (Sections 1 and 6) and Form CX i. The QX categories "ships" and "vehicles and aircraft" have been merged on CX, meaning that the old QXXLD and QXXLF both map to the new CX4, and the old QXXLE and QXXLG map to the new CX5. ii. Additional items have been added within "Plant and machinery" (QXXLH & QXXLJ / CX6 & CX7). These require reporting institutions to record their acquisitions and disposals of “computers and other processing equipment”, and their acquisitions of computer software. Additionally, the computer software acquisitions need to be reported as “developed in-house”, “purchased under licence payments” or “purchased outright”. These additional items have been added to improve the ONS’s measurement of investment in information technology. iii. The QX categories QXXFDB (finance leases to UK financial corporations other than monetary financial corporations) and QXXFEB (finance leases to UK financial unlimited liability partnerships) have been combined on Form CX, as have QXXFFB (finance leases to UK nonfinancial corporations) and QXXFGB (finance leases to UK non-financial unlimited liability partnerships). 2) Differences between Form QX (Sections 4 and 5) and Form WO i. Unlike section five of the Form QX which is reported in a different way in the fourth quarter of each year, the Form WO will be reported in a consistent way every quarter (ie. relating to writeoffs made in the quarter). ii. Item WO1HA (formerly QXXKJA) has been renamed “real-estate” to bring the item into line with Forms AD and AL. iii. The "unlimited liability partnership" items on the old QX section five have been removed: hence the old boxes QXXKG (financial corporations other than monetary financial institutions) and QXXKH (financial unlimited liability partnerships) have been merged to form the new WO1G; similarly the old QXXKJ (all non-financial corporations (excluding unlimited liability partnerships) other than public corporations and QXXKK (non-financial unlimited liability partnerships) have merged to form WO1H. 3) Differences between Form QX (Section 7) and Form HF The basis of reporting has been changed to an “immediate investor” basis. In cases where the country of ultimate investor is different from the immediate investor, equivalent details are required. The separate reporting of preference shares and bonds and other capital is no longer required. SRTN2007/01 Page 9 of 15 8. Form DQ Implementation These changes come into effect for existing reporters on the return for end-December 2007 data. At present we do not expect any building societies to be required to report Form DQ. For clarity, the Bank is taking this opportunity to reorganise the definitions for Form DQ and these will be available on the Internet. Reporting Threshold The threshold for quarterly reporting of Form DQ has been set to total gross liabilities under contracts in financial derivatives (BT19BL) in excess of £5bn. It is discretionary – derivatives positions are volatile and so reporting institutions will not be recruited to the reporting panel until they report consistently large positions. Form Changes 1) Removals Sections 3, 4 and 6 of the Form DQ have already been removed; see Statistical Notices 2004/04 and 2007/02 for details. 2) Other Changes i. The treatment of interest rate swaps undertaken between reporting institutions and the SwapClear facility operated by LCH.Clearnet Limited (formerly known as London Clearing House) has been clarified. These should be reported in accordance with the sectoral classification of LCH.Clearnet Limited, that is, “UK financial institutions other than monetary financial institutions”. ii. The definition of credit derivatives captured by the return has been extended to include all credit derivative instruments. Credit default products, such as credit default swaps, which have previously been excluded, should be reported on the form. iii. Section Five, which captures cross border positions by country, will be renamed Section Three. 9. Form DM The Bank has formerly removed the Form DM (a monthly derivatives return developed in 1997) from the Yellow Folder as a monthly requirement is no longer envisage. 10. Forms HI and HO Implementation Building societies that are requested to report Forms HI and HO will start reporting from endDecember 2009 data. Those societies required to report forms HI and HO will be contacted in the first half of 2008. SRTN2007/01 Page 10 of 15 Reporting Thresholds Form HI – Inward foreign direct investments in excess of £20mn Form HO – Outward foreign direct investments in excess of £20mn Form Changes No changes have been made to the structure of Forms HI and HO, however the submission deadline has been extended by four weeks to sixteen weeks with immediate effect. 11. Forms PL, BG and ER Given they are relatively new forms the PL and ER forms have not undergone a full review and there are no changes to the content or definitions of these forms. An extensive reporting panel review has however been undertaken for Form PL, the initial outcome of which is a move away from PL being reported by all institutions. This also affects the reporting panel of Form BG. Implementation Building societies that are requested to report Form PL on a quarterly basis will start reporting from end-March 2008 data, while those required to report on an annual basis will start reporting from end-December 2009 data. Those societies required to report Form ER will start reporting from end-January 2008 data. Those societies required to report Form BG on a quarterly basis will start reporting from end-March 2009 data. Those societies required to report Form BG will be contacted in the first half of 2008. Reporting Threshold i. A new threshold for annual reporting of the PL and the BG has therefore been set. This is discretionary based on total assets as reported on the BT (BT40) but any entity with less than £250 million of total assets will be released from reporting Forms PL and BG. There is also likely to be a further review of the thresholds for annual reporting during 2008 or 2009. ii. The threshold for quarterly reporting of Form PL remains at around £1 billion of total assets as reported on Form BT for the time being. The threshold for quarterly reporting is likely to be increased considerably later this year for 2008 reporting. iii. On the basis that annual reporting thresholds are likely to be reviewed again and the set up costs for reporting Form PL can be significant we will only ask societies that are likely to meet the revised threshold for quarterly reporting to report in 2008 and review the annual reporting requirements during 2008 for reporting 2009 data. iv. The threshold for quarterly reporting of Form BG remains discretionary depending on the level of non-resident business. Generally banks reporting Form PL quarterly and with a significant amount SRTN2007/01 Page 11 of 15 of non-resident business are asked to report Form BG and similarly this will apply for societies but only from 2009. In practice we believe this will mean very few societies will be required to report Form BG. v. The threshold for Form ER remains a representative panel based on institutions’ business with different sectors of the economy. Bank of England Monetary & Financial Statistics Division 21 March 2007 SRTN2007/01 Page 12 of 15 BANKING STATISTICS - REPORTING PANEL CRITERIA Reporting institutions should note that the promotion/demotion criteria are for guidance only. In certain circumstances, for instance rapid growth in business or a large loan book acquisition, the Bank reserves the right to call for returns sooner than the table might suggest. FORM CRITERIA PROMOTION/DEMOTION TIMETABLE BT (monthly) Sterling eligible liabilities (BT£46) in excess of £400mn (positive or negative), or private sector holdings (BT items £2H + £3H or £29D) in excess of £1bn. Two full calendar quarters breaching the threshold. Change effective the first end quarter thereafter (or immediate if required to place a CRD or the reporter is otherwise required by the FSA). Or, as soon as a reporter is required to place a cash ratio deposit (CRD) with the Bank. Further reporters may be required to submit monthly balance sheet data by the Financial Services Authority (FSA). BT (quarterly) All reporting institutions which are not monthly BT reporters. As monthly BT. BE As monthly BT. As monthly BT. AD As monthly BT. As monthly BT. AL As monthly BT. As monthly BT. Section A Outstanding loans on residential property greater than £1,500mn. Two calendar quarters breaching the threshold. Change effective immediately. Section B Outstanding credit card balances greater than £100mn. As Q1(D) Section A. Section C Outstanding sterling other loans and advances and overdrafts greater than £100mn. As Q1(D) Section A. Outstanding loans on residential property greater than £1,500mn. Two calendar quarters breaching the threshold. Change effective immediately. Q1(D) IS SRTN2007/01 Page 13 of 15 FORM CRITERIA PROMOTION/DEMOTION TIMETABLE IC Outstanding credit card balances greater than £100mn. Two calendar quarters breaching the threshold. Change effective immediately. IO Outstanding sterling other loans and advances and overdrafts greater than £100mn. Two calendar quarters breaching the threshold. Change effective immediately. Part 1 Footings over £1bn or eligible liabilities over £100mn. Two calendar quarters breaching the threshold. Change effective the second end quarter thereafter. Part 2 Section discontinued – (see Stats Notice 2006/05) Part 3 Section discontinued – (see Stats Notice 2006/05) Part 4 Footings over £1bn or eligible liabilities over £100mn. As QX Part 1. Part 5 Footings over £1bn or eligible liabilities over £100mn. As QX Part 1. Part 6 Footings over £1bn or eligible liabilities over £100mn. As QX Part 1. Part 7 Footings over £1bn or eligible liabilities over £100mn., plus any reporting institutions which have reported inward or outward direct investment holdings on Forms HI/HO. Two full quarters breaching the threshold, or identified on other returns. At second end quarter after being asked to complete. QX CX To be completed by reporters Reviewed annually – with end year specifically requested to do so by data. Change effective the end the Bank of England. quarter thereafter. Reporters are chosen on the basis of amounts of capital expenditure or finance leasing reported on the BT and PL forms. WO DQ PL (quarterly) PL (annually) To be completed by reporters specifically requested to do so by the Bank of England. Reviewed annually – with end year data. Change effective the end quarter thereafter. Discretionary, but generally gross liability positions in derivatives (BT Item 19BL) over £5bn. Two calendar quarters breaching the threshold. Change effective the second end quarter after being requested to report Discretionary, but generally footings over £1bn. Reviewed annually. Change effective from the second full quarter after being notified. Discretionary, but footings of at least £250mn. Reviewed annually. Timing as notified by the Bank of England. SRTN2007/01 Page 14 of 15 FORM CRITERIA PROMOTION/DEMOTION TIMETABLE CA Business of £2bn in all non-sterling and non-euro currencies on either side of the balance sheet. Promotion after breaching threshold, effective second end quarter after breach. CC External assets in all currencies above £300mn Promotion after breaching threshold, effective second end quarter after breach. CL External liabilities in all currencies above £300mn Promotion after breaching threshold, effective second end quarter after breach. ER A representative panel based on reporting institution’s business with different sectors of the economy. Reviewed periodically. Promotion to panel as notified by the Bank of England. BG (quarterly) Discretionary but generally reporting institutions reporting Form PL quarterly, that have significant business with non-residents. Reviewed annually. Change effective from the second full quarter after being notified. BG (annually) Discretionary but generally reporting institutions reporting Form PL annually that have a significant proportion of their business with non residents. Reviewed annually. Timing of promotion/demotion as notified by the Bank of England. HI £20mn of inward FDI levels as reported on the BT form. Reviewed annually. HO £20mn of outward FDI levels as reported on the CC form. Reviewed annually. HF £100mn of inward or outward FDI as reported on the HI and HO forms. Reviewed annually. C1 As required by the MFSD/FSA based on institution/group external business. As notified CE As required by the MFSD/FSA based on institution/group external business. As notified SRTN2007/01 Page 15 of 15